Search - consideration

Results 1741 - 1750 of 1907 for consideration
Ruling

2009 Ruling 2008-0304881R3 - Loss Consolidation

The Lossco Preferred Shares will not be, at any time during the implementation of the Proposed Transactions described herein: a) the subject of any undertaking that is a guarantee agreement; b) the subject of a dividend rental arrangement; c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or d) issued for consideration that is or includes: I. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b) of the Act); or II. any right of the type described in subparagraph 112(2.4)(b)(ii) of the Act. 32. ...
Ruling

2009 Ruling 2008-0294391R3 - transfer to and from a XXXXXXXXXX foundation

The former shareholders of Foreign Co 1 received no consideration on the amalgamation; whereas the former shareholders of Foreign Co 2 received shares of Foreign Co 1 on the amalgamation. ...
Ruling

2009 Ruling 2009-0343391R3 - Partnership Reorg-Personal Services Business

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 26. ...
Ruling

2016 Ruling 2015-0617351R3 - payments under a German profit transfer agrmt “PTA"

FA2 and New FA3 will enter into a share-for-share transfer agreement pursuant to which all the shares of FA5 owned by FA2 will be transferred to New FA3 in consideration for additional shares of New FA3. ...
Ruling

2017 Ruling 2016-0635341R3 - Canadian Exploration Expenses - New Mine

In XXXXXXXXXX, ACo granted to XXXXXXXXXX an XXXXXXXXXX in consideration for $XXXXXXXXXX in exploration expenditures and the production of a bankable feasibility study by XXXXXXXXXX. 15. ...
Ruling

2008 Ruling 2007-0246051R3 - Partnership Reorg- personal services business

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 26. ...
Ruling

2008 Ruling 2007-0251531R3 - Partnership Restructuring

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 29. ...
Ruling

2008 Ruling 2007-0251731R3 - Partnership Reorganization

Pursuant to the Contract and in consideration for a fair market value fee, the Partnership will provide the Contracting Company with certain facilities, equipment, supplies and personnel that are required to provide the Professional Services. 22. ...
Ruling

2016 Ruling 2015-0624601R3 - Loss Consolidation

The Issued Canco Preferred Shares will not be, at any time during the implementation of the proposed transactions described herein: (a) the subject of any undertaking that is referred to in subsection 112(2.2) of the Act as a “guarantee agreement”; (b) the subject of a dividend rental arrangement as that term is defined in subsection 248(1) of the Act; (c) the subject of any secured undertaking of the type described in paragraph 112(2.4)(a); or (d) issued for consideration that is or includes: i. an obligation of the type described in subparagraph 112(2.4)(b)(i), other than an obligation of a corporation that is related (otherwise than by reason of a right referred to in paragraph 251(5)(b)); or ii. any right of the type described in subparagraph 112(2.4)(b)(ii). 18. ...
Ruling

2007 Ruling 2006-0213701R3 - Partnership Reorganization Personal Services Bus.

Pursuant to a written agreement and in consideration for a fair market value fee, Partnership A will provide the Contracting Companies with certain supplies, personnel, facilities and equipment that are required to provide XXXXXXXXXX Services. ...

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